Previous Code
Main Page
GO 165 Startup Page
Search GO 165
Next Code

General Order 165
II.    Inspection

Cycles D.96-11-021 proposed inspection cycles for various types of distribution facilities and equipment, including wood poles. We herein adopt the inspection cycles presented in Appendix A of this order, which are those we proposed in D. 96-11-021 except where noted below.

A)    Comments of the Parties

ORA comments that some of the inspection cycles proposed in D.96-11-021 are actually less stringent than those proposed by one or more of the utilities for certain types of facilities. ORA believes the result of adopting more lenient inspection standards will be to reduce the frequency of corresponding maintenance and repair. ORA believes the Commission should adopt the utilities' maintenance plans in recognition that different utility systems require different inspection cycles. TURN makes similar comments, arguing that the utilities should not be permitted to extend their inspection cycles.

Edison suggests several specific modifications to the proposals in D.96-11-021. It recommends that inspection cycles for wood poles that have previously passed intrusive inspections be extended to 20 years. It suggests that detailed inspections of underground, padmounted, and overhead equipment and facilities be extended to every six years.

Edison also comments that the utilities cannot visually inspect underground cable because most of it is buried in conduit or directly in the ground. It observes that underground cable is an extremely reliable part of its system and does not require regular inspections.

PG&E objects to a requirement that underground and padmounted facilities be visually inspected every year, arguing that such inspections or patrols will result in few, if any, findings of deterioration of degradation. It comments that problems resulting from overgrown vegetation would be identified during three-year inspections. It believes the cost of annual inspection would exceed the benefits.

Sierra proposes a five-year inspection cycle for underground facilities and asks the Commission to designate all of its territory as "rural."

SDG&E states that its service territory varies in many ways, both internally and as compared to the other utilities in California, and believes that, where appropriate, these variances should be recognized to avoid potential unnecessary expenditures.

Pacific proposes numerous changes to the inspection cycles proposed in D.96-11-021 but does not justify them. We therefore have no basis upon which to make the modification Pacific proposes.
B)    Discussion
We adopt the inspection cycles set forth in Appendix A, which are in some cases different from those we proposed in D.96-11-021. These changes are made in response to the comments we received from the parties.

We adopt Edison's recommendation to extend the inspection cycle to 20 years for wood poles that have previously passed intrusive inspections. Edison convinces us that, based on its experience, this interval is reasonable where a pole has passed such an inspection. We also modify our proposal to exclude underground cable from regular inspections, as Edison proposes, because such inspections appear impractical and unnecessary.

Edison does not justify a six-year inspection cycle for other facilities except to say its practice is to inspect on a "continuous" basis. If that is true, Edison should not object to the inspection cycles we adopt today, which are the same as we proposed in D.96-11-021. PG&E does not convince us to eliminate annual visual inspections of underground and padmounted facilities. Based on our review, such inspections appear consistent with industry practice and may be conducted during the course of other business.

Similarly, Sierra fails to justify its suggestion to reduce the proposed inspection cycles for underground facilities and we therefore reject this suggestion. We also decline to designate Sierra's territory as "rural," since we have no evidence upon which to base such a finding and the matter is outside the scope of this rulemaking. We do, however, modify the General Order to specify definitions of "urban" and "rural." As Edison suggests, we will define "urban" as an area populated by more than 1,000 persons per square mile, a definition used by the United States Bureau of the Census.

We reject SDG&E's apparent suggestion that the utilities should have discretion to determine appropriate inspection cycles, except to the extent the utilities have discretion to inspect facilities more frequently than the standards require. SDG&E raises the point that its territory may be significantly different from that of other utilities in California. We have already taken into account the various considerations laid out in Section 364 (b) in developing our statewide standards. But, in developing statewide standards, significant issues of local geography and weather may be obscured. We do not have a sufficient record in this case to develop different standards tailored to the huge variety of local terrains and climates in our large and complex state, and cannot in this order adopt the multitude of different standards implied by SDG&E's statements.

In D.96-11-021, we stated our intent to adopt general inspection standards and place the burden on utilities to request and define legitimate exceptions. We required that exceptions must be very specific, and supported by data, as well as documentation of enforcement consequences. We stated that we will reject vague references to geography or facilities, and required that exemptions be narrowly defined.

The limited exemptions contemplated in D.96-11-021 were to be proposed in comments on the proposed standards set forth in that decision. Since we did not receive detailed, specific comments proposing exemptions, we adopt none at this time. However, we will allow SDG&E or the other respondent utilities to file a further application, if they choose, to propose standards based more closely on local geographic and weather conditions in their territories, to the extent that such an application is consistent with the guidelines discussed in D.96-11-021.

We have previously addressed the suggestions of ORA and TURN that we hold the utilities to their existing inspection cycles where they are more frequent than the ones we adopt today. This inquiry is a rulemaking, not a reasonableness review. We adopt the inspection cycles in Appendix A after considering industry practice and after review of relevant documents and proposals. We have already stated that the standards we adopt today are maximum acceptable lengths for inspection cycles. In certain circumstances, it may be prudent to conduct more frequent inspections to assure high-quality service and safe operations. In those cases, the utilities are responsible to inspect facilities more frequently.

We address the concerns of ORA and TURN that we should adopt maintenance and repair standards by commenting that our decision to adopt performance standards, rather than prescriptive ones, for such activities, does not in any way relieve the utilities of their obligations to maintain their systems according to industry standards and in ways which would promote high-quality service and safe conditions. As we stated in D.96-11-021, we decline to develop prescriptive standards at this time because we believe performance standards will provide adequate incentives while allowing the utilities to determine the specific methods of maintaining their systems. We will consider prescriptive standards if and when evidence ultimately demonstrates their necessity.